INTRODUCTION

This is the Privacy Policy for all websites owned or operated by COCOPLUM BEACH & TENNIS CLUB, INC. (“CocoPlum”), located at 109 Coco Plum Drive Marathon Florida 33050, including, without limitation the following websites: cocoplum.com, 27avenuef.com (each a “Site” and collectively, the “Sites”). Your access to and use of the Sites is subject to this Privacy Policy and all applicable laws. Your privacy rights are important to us, and we want to make sure you are comfortable providing information to COCOPLUM when you wish to rent or inquire about a property listed on one of our Sites. The terms “COCOPLUM”, “we”, “us” and “our” when used in this Privacy Policy refer to COCOPLUM and its various affiliated entities. The terms “you” and “your” when used in this Privacy Policy means a user of any of the Sites.

This Privacy Policy is part of and incorporated into the Terms of Use for our Sites. Any other capitalized terms used in this Privacy Policy but not defined in this document will have the meanings as defined in the Terms of Use for our Sites.

Following notice to you or your acknowledgement of this Privacy Policy (including any updates), your continued use of any of our Sites indicates your consent to the practices described in this Privacy Policy.

SCOPE OF THIS PRIVACY POLICY

COCOPLUM Sites

This Privacy Policy applies only to Information (defined below) collected through our Sites, and it does not govern any Information you may provide to us or our partners or affiliated companies by phone or otherwise.

Third party sites and services

Third party sites, including our advertisers, promotional partners, property owners or managers, and other service providers accessible through our Sites, or third-party sites and services on which we advertise, may have their own privacy and data collection policies and practices. For example, during your visit to our Sites you may link to, or view content that is created or hosted by a third party. COCOPLUM is not responsible for the actions or policies of such third parties and is not liable to you for any claims that may arise from your interaction with those third parties or their sites. You should check the applicable privacy policies of those third parties when providing personal information on a feature or page operated by a third party.

Ownership of Information

If you provide Information to COCOPLUM on a COCOPLUM owned and operated Site, COCOPLUM is the owner and controller of that Information, and we may process and share it as described in this Privacy Policy. However if you provide Information directly to a third party, that third party is the owner and controller of the Information, and in some cases they may share it with COCOPLUM.

INFORMATION COLLECTED ON OUR SITES

We may collect and process information that relates to identified or identifiable individuals (“Personal Information”) when you use our Sites. We also collect other information (“Other Information”) which alone does not identify you (however, in some circumstances Other Information may be combined with Personal Information in order to identify a specific individual). We sometimes refer to both Personal Information and Other Information in this Privacy Policy as “Information.” We may collect the following types of Information on our Sites (these are merely examples, and may change over time):

Information you voluntarily provide

In order to access or use certain services and capabilities on our Sites, you may be required to voluntarily submit Personal Information. The use of these services or capabilities is purely optional, so you are not required to submit any Personal Information through our Sites if you do not wish to use them. Some of these capabilities include requesting information on a particular rental property or vacation destination, providing details regarding a property you own or manage (for potential listing on our Sites), or Information you provide when you otherwise contact us through our Sites. You may provide this information directly to our Sites, or to third parties who share the information with us. Voluntary Personal Information you provide may include:

· Identity and contact data, such as your name, email address, physical address, phone number, username, and other Personal Information you may provide on registration and when you list rental properties with our Sites or when you rent properties through our Sites.

· Feedback or other information you provide when you contact us through the Sites.

· Information relating to your preferences and interests, such as your “likes” or “favorites.”

Information collected automatically

When you use our Sites, some types of Information will be automatically collected, even if you don’t participate in a transaction. This may include:

Information relating to your computer, device, browser, or application, such as your IP address, the hardware, software or internet browser you use, your computer’s operating system, which versions of certain applications you were using, and other data generated through applications and browsers, including cookies and similar technologies.
The date/time you accessed our Sites, the referring site, pages you visited and content you viewed when you were on our Sites, other session navigation history, and similar browsing metadata.
If you access our Sites on a mobile device, we may collect data identifying your device, including location details (if you have location enabled on your device).

Information we receive from third party sources

We may receive Personal Information from third party sites (including our affiliated companies and unrelated sites) on which you book your reservations or make inquiries, and from sites on which we advertise properties. These third parties may share your name, contact details, properties, dates and other details regarding your booked or potential transactions, or other Information with us. Some Information you provide to the third parties may be retained by them for their own business purposes and may not be shared with us.

USE OF INFORMATION COLLECTED ON THE SITES

COCOPLUM or our affiliated companies may use, and process Information collected on our Sites for the following purposes:

If you book a vacation rental through our Sites, we use your contact information, payment information, transaction details, and other Information you provide in connection with a rental to facilitate a transaction between our users and property owners or managers, including processing payments, emails or phone calls relating to a transaction, and providing related services as needed.
We use your contact details and other Information you provide in various communications with you, such as when responding to your inquiries, reminding you to complete a transaction you may have started, reminders about your upcoming stay, and customer service related messages.
If we process Personal Information in connection with our Sites in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to Your Rights and Choices, below) unless otherwise stated when you provide it.

SHARING OF INFORMATION

We may share Information collected through our Sites with various third parties as follows:

In order to facilitate your transaction, streamline our business operations, improve our services, and develop products and services that better meet your interests and needs, we may share all of your Information with our current or future affiliated entities, subsidiaries, and parent companies.
If you make a payment for a rental or subscription on our Sites, or if we need to pay you in connection with a rental, we may share payment related information and contact data or transaction details with payment providers and relevant financial institutions as needed to process your payment or in connection with a chargeback or for fraud detection and prevention purposes, and we may also share limited payment information (such as confirmation of a payment being processed, or sending a check for payment) with the property owner/manager or our affiliated entities.
We share relevant Information with companies and organizations that perform services on our behalf (as applicable depending on the services they provide). For example, Information may be accessed by or shared with companies that provide support services to us (such data storage, web hosting, email services, marketing services and other services).
If we determine in good faith, that disclosure is appropriate to comply with the law (or respond to any legal process such as a court order or subpoena, government requests in the U.S. or other countries, or a request related to national security in accordance with applicable laws) we will share Information to the extent we believe necessary.
We may share Information regarding transactions, payment information, contact information, and other details as may be necessary, with law enforcement, property owners, affiliated entities, or others in order to prevent or investigate a possible crime such as fraud or identity theft, or to protect and defend the rights, properties, or safety of property owners/managers, COCOPLUM, our affiliated companies or third parties, including to enforce the Terms of Use or other agreements that govern your use of our Sites or rental of properties you have identified through our Sites.
In the event of a natural disaster or other circumstances, we will share information as needed to protect the vital interests of guests, property managers, business partners, our employees, and others.
In connection with corporate transactions, any information collected on our Sites, including without limitation Personal Information, may be transferred to any entity related to COCOPLUM or any of its affiliated entities in the future, or to another company that has acquired the stock or assets of COCOPLUM or our affiliated companies, for example, as the result of a sale, merger, reorganization, dissolution or liquidation. If such a transfer occurs, the acquiring company’s use of your Personal Information will still be subject to this Privacy Policy, and the privacy preferences you have expressed to us.

COOKIES, TRACKING TECHNOLOGIES AND ADVERTISING

Cookies and Tracking Technologies

We utilize “cookies”, “tags”, “pixels”, “clear gifs” and other similar tracking technologies on our Sites. A cookie is a text file that is placed on your computer or other mobile device when you access the Sites or the Internet. These technologies allow us or our third-party partners or service providers to collect Information about your interaction with our Sites and advertisements. Examples of such Information may include, but are not limited to: demographic Information, browser type, IP address, pages viewed, activity conducted, and timing of your visit. You may at any time opt out of certain tracking mechanisms through your browser settings. However, disabling such features may prevent you from using certain features or taking full advantage of all of our offerings on our Site.

Different types of cookies are used for different purposes on our Sites. These are known as: strictly necessary cookies, performance cookies, and functionality cookies. Some cookies may be provided by an external third party to provide additional functionality to our Sites and these are included below.

Strictly necessary cookies. These are cookies that are essential to fulfil an action requested by you, such as identifying you as being logged in. If you prevent these cookies by adjusting your browser settings we cannot guarantee how our Sites will perform during your visit.
Performance cookies. These are cookies used to improve our Sites, for example for analytics that let us see how a Site is being used and where to make improvements. These cookies are used to collect Information about how visitors use our Sites. The Information is collected in an anonymous form and includes the number of visitors, where visitors have come from to the Sites and the pages they visited.
Functionality cookies. These cookies enhance the performance and functionality of our Sites, often as a result of something you’re doing as a user. For instance, we may personalize our content for you or remember your preferences (such as your favorite locations or properties).

COCOPLUM, our trusted service vendors/providers, and permitted third parties may also advertise our properties and services on third-party websites. Third-party websites may also use cookies or other tracking devices. We do not have control over the tracking technologies utilized by third-party websites. As such, you should carefully review the privacy policies of those third-party sites to understand their tracking activities, if any.

Do Not Track Requests

We will automatically collect cookies and other information when you visit our Sites. Due to this automatic collection, we do not currently honor browser based “do not track” requests. We currently participate in third party ad networks and use third party cookies as discussed above to track your visits across websites. For information on how to opt-out of the collection of Information by other tracking devices please see Your Rights and Choices below.

Disabling Cookies on Your Browser

You may refuse or delete cookies on our Sites. Please refer to your browser Help instructions to learn more about cookies and other tracking devices and how to manage their use. If you choose to refuse or delete cookies, some of the functionality of our Sites may be impaired. If you use another computer or change browsers, you will need to repeat the process of refusing or deleting cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.

Behavioral Advertising

We, and certain third parties operating on or through our Sites, may engage in online behavioral advertising. This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising: This form of advertising may use information regarding your identity, preferences, devices, and sometimes your email address or other contact data in order to deliver more relevant advertising to you. The parties that control the processing of Personal Information for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services after viewing an advertisement. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to and determine whether and how ads you see are effective, and may augment your profile with information derived from these observations. See Your Rights and Choices for information about how you can limit or opt out of this processing.

YOUR RIGHTS AND CHOICES

It is possible for you to use some of our Digital Services without providing any Personal Information, but you may not be able to access certain features or content. You have the following choices regarding the Personal Information we process:

Direct Marketing. You have the choice to opt-out of our marketing communications at any time by clicking on the unsubscribe link in emails generated by our third-party email provider. If an individual sales representative sends an email specifically to you, there is no unsubscribe link in that email, however you may notify us by forwarding the email to info@cocoplum.com and notifying us that you do not wish to be contacted again.

Other Consent. If you have provided consent to any specific processing of your Personal Information, you may withdraw consent any time, to the extent required by law.

Cookies & Similar Technology. If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out. Our Sites do not respond to your browser’s do-not-track request.

Behavioral Advertising: You may opt out or withdraw your consent to behavioral advertising. You must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here. To opt out from Facebook Custom Audience Pixel, visit their customer support page here. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonpPersonal Information.asp. You can limit or opt out of our processing for behavioral advertising by contacting us.

Other Processing. You may have the right under applicable law to object to our processing of your Personal Information for certain purposes. You may do so by emailing us at info@cocoplum.com re: data rights requests. Note that we may not be required to cease processing based solely on an objection.

Residents of the EU have certain additional rights in their Personal Information under EU law. Please see Additional Information for EU Residents below.

Residents of California (and others as required by applicable law) may request a list of Personal Information we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us at 109 Coco Plum Drive, Marathon, FL 33050.

INTERNATIONAL USERS

If you are located outside of the United States, you understand that by using any of our Sites, you are providing Information to COCOPLUM and its affiliated companies and processors in the United States, and you are voluntarily transferring your Information to the United States in connection with a contract you are entering in relation to a property, or otherwise based on your consent. This transfer of certain Personal Information to the United States is necessary in order to fulfill a contract for booking with COCOPLUM or our affiliated companies. For more information about how we transfer Personal Information in accordance with specific EU data privacy legislation please the Additional Information for EU Residents section below.

SECURITY AND DATA RETENTION

We follow and implement reasonable security measures to safeguard the Personal Information you provide us. However, we sometimes share Personal Information with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically.

MODIFYING OR DELETING YOUR INFORMATION

We respect your right to make choices about the ways we collect, use, process and disclose your Personal Information. You may update or delete your information or change your preferences at any time by sending an email to info@cocoplum.com.

ADDITIONAL INFORMATION FOR EU RESIDENTS

Legal Basis for Processing

All processing (i.e., use) of your Personal Information is based on one of a number of legal conditions. Generally, these will be:

Your consent (for example, to place cookies which process Personal Information, or for marketing from our third-party partners);
The performance of our contract with you (e.g., to process your rental transaction, or to list your property on our Sites, to share your Information with third party property owners/managers, or payment processors);
Compliance with a legal obligation (e.g., where we are required to disclose information to a court or a tax authority); and
Our legitimate interests provided these do not override your fundamental rights and freedoms (e.g., where we carry out our own direct marketing to guests or property owners who have provided information to us, subject to your right to opt-out of this at any time).

Rights of EU Residents

Subject to applicable law, as a resident of the EU, you may have some or all of the following rights in respect of your Personal Information:

To obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed;
To rectify inaccurate Personal Information (including the right to have incomplete Personal Information completed);
To erase your Personal Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
To restrict processing of your Personal Information where:
- The accuracy of the Personal Information is contested;
- The processing is unlawful but you object to the erasure of the Personal Information;
- We no longer require the Personal Information, but it is still required for the establishment, exercise or defense of a legal claim;
To challenge processing which we have justified based on a legitimate interest (as opposed to your consent, or to perform a contract with you);
To prevent us from sending you direct marketing;
To withdraw your consent to our processing of your Personal Information (where that processing is based on your consent);
To object to decisions which are based solely on automated processing or profiling; and
To obtain or see a copy of the appropriate safeguards under which your Personal Information is transferred to a third country or international organization.

In addition to the above, you have the right to lodge a complaint with your local supervisory authority (for example, the ICO in the United Kingdom).

In relation to these rights, please contact us at info@cocoplum.com. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will use reasonable efforts to respond to your requests within applicable timeframes.

International Transfers for EU Residents

You should be aware that we are a U.S. headquartered company, and your Personal Information will routinely be transferred to and stored in the United States for processing. Although COCOPLUM does not itself transfer Personal Information from the European Economic Area ("EEA") to the U.S, if we receive Personal Information from third parties in the EEA, we will comply with the GDPR or other applicable legal requirements with regard to the transfer and processing of that data, to the extent those laws govern the transfers.

CHANGES TO THIS PRIVACY POLICY

Your use of the Sites and continued use of the Sites following any changes to the Privacy Policy, signifies that you agree with the terms and conditions of the Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites or provide any Information to us.

We may update this Privacy Policy from time to time by posting additions or modifications to this page, so we encourage you to periodically review this Privacy Policy.

To help you stay current of any changes, we take the following two steps: (i) we note the date the Privacy Policy was last updated above; (ii) when we make a material change to the Privacy Policy, we will indicate the change by posting a notice on our Sites next to the link to this Privacy Policy or we send an email to all users for whom we have Personal Information. Your use of any Site following the posting of any revised Privacy Policy shall be deemed acceptance of the revised policy, so we strongly recommend that you review the Privacy Policy periodically.

QUESTIONS

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please email us at info@cocoplum.com.